EXH0176018444

PCHBPollution Control Hearings Board of the State of Washington

The last time I spoke with Jim Kelley (last week) I suggested the Port initiate a bird monitoring program at the two in-basin mitigation sites (Vacca Farm, Tyee Golf Course). I suggested the Port still has time to get a full year of bird use data at the sites before they are revegetated into native wetland plant communities. suggested the Port and the FAA needed these data in order to assess whether the mitigation actions result in a net increase of BASH (bird-aircraft strike hazard). Jim was a bit surprised by my suggestion, I think. He countered that he didn't think the FAA would need such data to evaluate a problem. Rather, they would monitor the mitigation sites and determine if they had unacceptable congregations of birds. If so they would take action. In other words, it isn't the net increase in hazard that would trigger a wildlife suppression action but rather the existence of the hazard. While I agree with this, I told Jim I was concerned that the FAA and the Port could use the existence of a hazard to "prove their point" that wetland mitigation areas increase the hazard. . Jim is in the process of defining potential problem situations better, describing the control actions that the FAA would likely take to control such situations, etc etc. I told Jim we would want the FAAand the Port to agree with us that the lack of "before" bird use at the mitigation sites will invalidate any future claims…
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